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510(k) Data Aggregation
(773 days)
Under the supervision of a healthcare professional, Venus Ag may be used for the management of:
- · wounds with moderate to heavy exudate
- · partial thickness burns
- · leg ulcers, pressure ulcers and diabetic ulcers
- · surgical wounds (e.g. post-operative, wounds left to heal by secondary intent and donor/graft sites)
- · traumatic wounds (e.g. abrasions and lacerations)
- wounds that are prone to bleeding, such as wounds that have been mechanically debrided and donor sites.
The product is for a single use only.
Venus Ag 120, 160 and 200 Wound Dressing with Antimicrobial Silver and Strengthening Cellulose Fiber are a soft, conformable non-woven fabrics made from sodium carboxymethyl cellulose and strengthening cellulose fiber(s) with antimicrobial silver. The silver in the wound dressing, when in contact with wound exudate or blood present in wound exudate, has an antimicrobial effect on bacteria held within the dressing, preventing it from being colonized. The absorption of exudate into the dressing forms a gel which assists in maintaining a moist wound environment, supporting autolytic debridement, protects the wound edge and surrounding skin from maceration. Through the gel formation the structure of the dressing remains intact. Debris and any bacteria found in the wound exudate can be retained inside the dressing and removed when the dressing is changed. When dry, Venus Ag can easily be cut to the size of the wound.
The device is a combination product, code FRO.
Venus Ag dressings are supplied in a variety of sizes, configurations, and weights.
The provided text describes the regulatory clearance of a medical device (Venus Ag 120, 160, and 200 Wound Dressing) by the FDA, primarily by establishing substantial equivalence to existing predicate devices. However, it does not contain a typical study design with acceptance criteria for device performance in the sense of a clinical trial or a standalone algorithm-only study for AI/ML devices.
Instead, the document details non-clinical performance testing (bench testing), biocompatibility testing, and a porcine wound healing study to demonstrate that the Venus Ag wound dressing is as safe and effective as its predicate devices.
Here's an attempt to structure the information based on your request, acknowledging that some of the requested fields are not directly applicable to this type of device clearance and the information provided:
Acceptance Criteria and Device Performance
The device's acceptance criteria are framed in terms of meeting established standards (ISO, British Pharmacopoeia, European Standard) and demonstrating equivalence to predicate devices, rather than specific quantitative performance metrics against a clinical outcome.
Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criteria / Standard Met | Reported Device Performance |
---|---|---|
Antimicrobial Efficacy | Modified AATCC 100: Log 4 reduction within the dressing against gram-negative, gram-positive, yeast, and mould. | Consistently met the requirement of a log 4 reduction within the dressing when compared to a control. |
Silver Release Profile | Equivalent to predicate device in simulated wound fluid over 24 hours, 5 days, and 7 days. | Found to be equivalent to that of the predicate device. Silver content remained stable throughout accelerated and real-time stability studies. |
Absorbency | British Pharmacopoeia; Test Method for absorbency of Alginate dressings/Surgical dressings, and European Standard EN13726-1: Must meet specified absorbency levels. | Consistently met specifications. |
Tensile Strength | British Pharmacopoeia: Must meet specified tensile strength. | Met the specifications set for this product. |
Biocompatibility | ISO 10993-1: Biological evaluation of medical devices. Specific tests: Cytotoxicity (ISO 10993-5), Intracutaneous Irritation (ISO 10993-10), Acute Systemic Toxicity (ISO 10993-11), Sub-acute Systemic Toxicity and Implantation (ISO 10993-6, 11), Sensitization (ISO 10993-10), Material Mediated Pyrogenicity (ISO 10993-11, USP, European Pharmacopeia), Biological and Toxicological Risk Assessment (ISO 10993-17). | All relevant biocompatibility studies were performed as per ISO 10993 standards. Testing demonstrated that the proposed device is as safe as the cleared 510(k) predicate device and does not raise new safety concerns. |
Wound Healing (Animal) | ISO 10993-6: No impairment of the wound healing process compared to the predicate and controls in a porcine model. | Did not impair the wound healing process as observed from histology parameters when compared to the predicate (Aquacel Ag+ Extra) and a control dressing. |
Sterilization Validation | ISO 11137-1 and ISO 11137-2: Meet predetermined acceptance criteria for sterilization. | Successfully met its predetermined acceptance criteria as per standards. |
Packaging Validation | ASTM F1886/F1886M, ASTM F1929, ASTM F88/F88M: Meet predetermined acceptance criteria for packaging integrity. | Successfully met its predetermined acceptance criteria as per standards. Packaging demonstrated appropriate maintenance of device integrity and sterility, also through accelerated aging studies. |
Shelf-life Testing | Maintain performance and integrity for a maximum shelf life. | A maximum shelf life of 24 months (based on real-time aged Final Finished Device) was assigned, stored unopened at ambient temperature. |
Overall Equivalence | No new questions of safety or effectiveness compared to predicate devices. | Non-clinical testing, including bench and animal studies, supports substantial equivalence to predicate devices (Titan Ag 200, Aquacel Ag Extra, Aquacel Ag+ Extra, Kerracell Ag), demonstrating it is at least as safe and effective for its intended use despite minor technological differences (e.g., silver content/formulation). |
Additional Study Information
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Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):
- The document refers to various non-clinical (bench) and biocompatibility tests. For these types of tests, "sample size" refers to the number of samples or specimens tested (e.g., dressings, materials). Specific numerical sample sizes are not explicitly stated in the provided text for each individual test (e.g., "5 samples for absorbency test").
- The "porcine wound healing study" is an animal study, not human clinical trial. No specific sample size (number of animals or wounds) is provided.
- Data provenance (country of origin, retrospective/prospective): Not specified in the document. These are non-clinical studies typically conducted in controlled laboratory environments.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience):
- This question is not applicable to the type of studies described. The "ground truth" for non-clinical tests is determined by adherence to established scientific standards, validated test methods, and quantifiable measurements, not expert consensus in the diagnostic sense. For the porcine study, histological analyses would be performed by trained pathologists, but the number and qualifications are not listed.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- This concept of adjudication (often used in clinical image review or complex diagnostic tasks) is not applicable to the non-clinical, bench, and animal studies described for this wound dressing.
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If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No, an MRMC comparative effectiveness study was not done. This type of study is relevant for AI/ML diagnostic or assistive technologies, which this wound dressing is not.
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If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- No, a standalone algorithm-only performance study was not done. This device is a wound dressing, not an AI/ML algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For antimicrobial efficacy: Established microbiological culture methods and count reductions, compared against controls.
- For silver release, absorbency, tensile strength: Material property measurements obtained through standardized analytical and mechanical testing methods.
- For biocompatibility: Histological analysis (for implantation and irritation), cytotoxicity assays, pyrogenicity tests, and systemic observation based on ISO 10993 standards.
- For porcine wound healing study: Histology parameters analyzed to assess the healing process (comparison to predicate and control).
- For sterilization, packaging, shelf-life: Standardized physical, chemical, and biological indicators and tests to confirm sterility, integrity, and stability within specified limits.
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The sample size for the training set:
- This concept of a "training set" is not applicable as this device does not involve AI/ML or a learning algorithm.
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How the ground truth for the training set was established:
- This question is not applicable as there is no "training set" for this device.
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(256 days)
Rx Only (Pad and ribbon Configurations)
Under the supervision of a healthcare professional, ALGS6 Ag Alginate Wound Dressing may be used for management of acute and chronic, partial and full thickness wounds including pressure ulcers, diabetic foot ulcers, surgical wounds, traumatic wounds, first and second-degree burns.
For Over-the-Counter use (Pad Configuration), ALGS6 Ag Alginate Wound Dressing may be used for:
- Minor Abrasions
- Minor Lacerations
- Minor cuts
- Minor scalds and burns
ALGS6 Ag Alginate Wound Dressing is a highly absorbent, sterile, single use, nonwoven (Rx version pad or ribbon, OTC version pad) dressing composed of calcium alginate fiber, Lyocell fiber and 1.7% ionic silver which allows for a maximum of 30.6 mg of silver for a 4-inch dressing (0.306 mg per square centimeter). Silver is present in the dressing as a preservative to prevent or inhibit growth of bacteria within the dressing. The dressing absorbs high amounts of wound fluid and the bacteria contained in the wound fluid. The absorbed wound fluid in the dressing creates a soft and cohesive gel which assists in maintaining a moist environment. The moist wound healing environment and control of dressing bacteria supports the body's healing process.
The provided document is a 510(k) summary for the ALGS6 Ag Alginate Wound Dressing, seeking substantial equivalence to a predicate device. It describes the device, its intended use, and comparative testing.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state formal "acceptance criteria" as pass/fail thresholds for clinical performance or diagnostic accuracy. Instead, it demonstrates substantial equivalence to a predicate device by comparing various performance parameters. The "acceptance criteria" can be inferred as being "substantially equivalent" to the predicate device in the parameters listed.
Parameter | Acceptance Criteria (inferred: Substantially Equivalent to Predicate) | Reported Device Performance (ALGS6 Ag Alginate Wound Dressing) | Proof of Criteria Met |
---|---|---|---|
Indications for Use (Rx Only) | Substantially Equivalent | Management of acute and chronic, partial and full thickness wounds including pressure ulcers, leg ulcers, diabetic foot ulcers, surgical wounds, traumatic wounds, first and second-degree burns. | Stated as "Substantially Equivalent" to predicate device, which also manages these wound types. The listed indications for both are very similar, covering a wide range of acute and chronic wounds. |
Indications for Use (OTC) | Substantially Equivalent | Minor Abrasions, Minor Lacerations, Minor cuts, Minor scalds and burns. | Stated as "Substantially Equivalent" to predicate device, which has identical OTC indications. |
Device Design | Substantially Equivalent | Highly absorbable, single layer, needle punched non-woven pad or ribbon dressing that can be cut or folded. | Stated as "Substantially Equivalent" to predicate device, which is also a highly absorbable, needle-punched non-woven pad dressing that can be cut or folded, though the predicate is described as two layers. The document argues this difference does not raise safety/effectiveness concerns. |
Mechanism of Action | Substantially Equivalent | Conformable, highly absorbent hydrophilic dressing that forms a soft, cohesive gel on contact with wound exudate which maintains a moist environment for optimal wound healing; ionic silver inhibits bacterial colonization of the dressing. | Stated as "Same" as the predicate device. Both are hydrophilic dressings that gel in contact with exudate, providing a moist environment and using ionic silver for antibacterial effects. |
Antibacterial Material | Substantially Equivalent | Ionic silver | Stated as "Same" as the predicate device. |
Antibacterial Effectiveness within the Dressing | Substantially Equivalent | Greater than 4 log reduction for 8 organisms (4 gram positive, 4 gram negative). | Stated as "Substantially Equivalent." While the predicate tested log reduction for 3 organisms and Zone of Inhibition for 19, the subject device demonstrated a strong log reduction for a broader range of tested organisms. The implication is that this level of antibacterial effectiveness is comparable or superior in performance. |
Hydrophilic Material | Substantially Equivalent | Alginate | Stated as "Substantially Equivalent." The document acknowledges the predicate uses sodium carboxymethylcellulose, but states that both materials perform the same primary function of absorption and moist wound healing, implying functional equivalence. |
Method of Affixation | Substantially Equivalent | Covered and secured with an appropriate secondary dressing. | Stated as "Same" as the predicate device. |
Wear Time per Dressing | Substantially Equivalent | Up to 7 days | Stated as "Substantially Equivalent." The predicate lists "Up to 7-14 days," but a 7-day wear time is considered within the range of equivalence. |
Integral Removal | Substantially Equivalent | Yes | Stated as "Same" as the predicate device. |
Single Use | Substantially Equivalent | Yes | Stated as "Same" as the predicate device. |
Biocompatible | Substantially Equivalent | Yes | Stated as "Same" as the predicate device. This is supported by specific biocompatibility testing (irritation, sensitization, acute systemic toxicity, animal wound healing study, pyrogenicity testing, subchronic systemic toxicity study). |
Sterilization | Substantially Equivalent | Gamma radiation (SAL 10-6) | Stated as "Same" as the predicate device. Supported by sterilization validation testing. |
Primary Packaging | Substantially Equivalent | Foil pouch | Stated as "Same" as the predicate device. Supported by packaging testing. |
Wound Healing Study | Non-inferiority to Predicate | Produced wound healing similar to the predicate device macroscopically and microscopically, and did not cause any delay in wound healing. | Animal wound healing study directly compared the subject device to the predicate device and found similar outcomes. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document primarily describes bench testing and an animal wound healing study for performance evaluation. It does not mention human clinical trials or a "test set" in the context of diagnostic performance (e.g., patient images or data used to evaluate an AI algorithm).
- Bench Testing: The sample size for each specific bench test (e.g., absorbency, silver content) is not specified.
- Animal Wound Healing Study: The number of animals or wounds studied is not specified.
- Data Provenance: The location of the testing is not explicitly stated. The manufacturer is in China, and the correspondent is in the USA.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This section is not applicable as the submission is for a wound dressing, not a diagnostic device that requires expert interpretation to establish ground truth for a test set. The wound healing study involved macroscopic and microscopic observation, likely by veterinary or histopathological experts, but their number and specific qualifications are not detailed.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This section is not applicable for the reasons stated above.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
This section is not applicable as the device is a wound dressing, not an AI-powered diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This section is not applicable as the device is a wound dressing, not an AI algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the performance testing:
- Bench Testing: The "ground truth" for parameters like absorbency, silver content, pH, and antibacterial effectiveness is established by standardized laboratory methods and measurements.
- Wound Healing Study: The "ground truth" for wound healing was based on macroscopic and microscopic observations of the wounds in animals, likely involving histopathological analysis (a form of pathology).
- Biocompatibility Testing: The "ground truth" is based on standardized toxicity and reaction tests in biological systems (e.g., irritation, sensitization, systemic toxicity).
8. The sample size for the training set
This section is not applicable as the device is a physical wound dressing and does not involve an AI algorithm with a "training set."
9. How the ground truth for the training set was established
This section is not applicable as the device is a physical wound dressing and does not involve an AI algorithm with a "training set" or corresponding ground truth.
In summary, the provided document describes a 510(k) submission for a wound dressing, focusing on demonstrating substantial equivalence to a predicate device through a series of bench tests and an animal wound healing study. It does not involve AI, human reader studies, or diagnostic performance evaluation with expert consensus ground truth, which are typically found in submissions for AI/CADe medical devices.
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